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Memo to Jim Stevens <br />"7emporary Abandonment" of New Elk <br />page 2 <br />failure. He projects that this would make it extremely expensive and <br />hazardous to attempt to reopen dewatered underground workings within the New <br />Elk mine. <br />Deterioration of Underground Equipment <br />The acidity of the waters flooding the underground workings would <br />significantly degrade any plumbing, wiring or equipment not removed from the <br />underground workings prior to abandonment. Realistically, if abandonment <br />lasted more than a few months the operator would have to replumb and rewire <br />the entire underground workings. This would represent a significant expense. <br />Water puality Considerations <br />In the event that the operator decided to recommission the abandoned <br />underground workings, an enormous volume of possibly contaminated water would <br />have to be bailed from the flooded workings. Pumping rates would be high, <br />requiring the installation expensive pumps. I believe it is likely that all <br />of this water would require treatment prior to release, which would constitute <br />another significant expense and environmental concern. Treatment plants and <br />sedimentation ponds would need to be sized to permit rapid dewatering. This <br />would significantly exceed the size of steady state facilities required for <br />maintenance of current operating conditions. <br />Conclusion & Recommendation <br />Based upon this brief analysis, conducted with the benefit of discussion with <br />Joe Nugent of the Colorado Division of Mines, I do not believe it is realistic <br />to assume that the underground workings at the New Elk underground coal mine <br />could be recommissioned if they were "temporarily abandoned" and allowed to <br />flood. If Wyoming Fue]s Company wants to pursue "temporary abandonment" they <br />will have to provide sufficient information to demonstrate that it is prudent <br />to believe that the underground workings could be recommissioned, and that <br />"temporary abandonment" would not present a hazard to the environment or the <br />health and safety of the public. <br />Failing such a demonstration, and upon expiration of Temporary Cessation <br />status, Wyoming Fuels should be required to complete reclamation of all <br />facilities of the New Elk mine, in accordance with the approved permit. Any <br />existing IJew Elk mine facilities necessary for the operation of the <br />neighboring Golden Eagle mine should be included within the Golden Eagle mine <br />permit through revision. <br />cc: Mike Long <br />